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<h1>Appeals to Appellate Tribunal require preliminary payment and may stay recovery pending tribunal determination.</h1> Appeals to the Appellate Tribunal against orders under sections 107 or 108 must generally be filed within three months; the Tribunal may refuse low-value appeals and may condone delay for sufficient cause. The Commissioner can call for records and direct applications to the Tribunal. Respondents may file verified cross-objections; appeals require payment of admitted liabilities and a portion of the disputed tax, which, once paid, stays recovery of the balance. Applications to the Tribunal must follow prescribed form, verification and fee requirements.